STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES AS MODIFIED

VINCE CHHABRIA, District Judge.

WHEREAS, Plaintiffs Indiezone, Inc. and eoBuy, Limited filed the Complaint on September 16, 2013, alleging twenty-seven counts against the above-named Defendants related to alleged misappropriation of Plaintiffs' intellectual property (ECF 1);

WHEREAS, the Jingit Defendants1 and Defendant U.S. Bank National Association ("U.S. Bank") stipulated with Plaintiffs for extensions of time to respond to the Complaint through January 10, 2014 (ECF 11-13 & 17);

WHEREAS, on January 10, 2014, the Jingit Defendants filed a: (1) Motion of Defendants Rooke and Rogness to Compel Arbitration with Indiezone, Inc. based on a mandatory arbitration clause in their employment agreements with Indiezone; (2) Motion to Dismiss Plaintiff eoBuy, Limited because this plaintiff dissolved in 2008 and lacked capacity to sue; and (3) Motion of Remaining Defendants to Stay All Remaining Proceedings pending the outcome of the arbitration (ECF 29);

WHEREAS, on January 10, 2014, Defendant U.S. Bank filed a motion joining the Jingit Defendants' Motions to Dismiss eoBuy, Limited and Stay All Remaining Proceedings (ECF 35);

WHEREAS, Plaintiffs filed a motion for leave to amend their Complaint to add or substitute a party on February 21, 2014, seeking to add "eoBuy Ventures Limited" as a plaintiff (ECF 57);

WHEREAS, on March 6, 2014, Plaintiffs, Jingit Defendants and U.S. Bank filed a Stipulation to Continue Initial Case Management Conference and Associated Deadlines based on the Parties' agreement that it would be inefficient to plan discovery, motions and other case management processes, including the Court's ADR Multi-Option Program, for a case in which one plaintiff may be dismissed and that may shortly be ordered to binding arbitration where different rules and procedures will govern (ECF 64);

WHEREAS, the parties to the March 6, 2014 Stipulation also agreed to combine the hearings on Defendants' and Plaintiffs' pending motions (ECF 64);

WHEREAS, on March 7, 2014, Defendant Target Corporation ("Target") joined Jingit Defendants' Motions to Dismiss eoBuy, Limited and Stay All Remaining Proceedings (ECF 69);

WHEREAS, on March 10, 2014, pursuant to the Parties' Stipulation, the Court ordered continuation of the case management conference until roughly two months after the joint hearing date for the pending motions (ECF 71);

WHEREAS, on March 11, 2014 Defendants Wal-Mart Stores, Inc. ("Wal-Mart") and General Electric Company ("General Electric") joined Jingit Defendants' Motions to Dismiss eoBuy, Limited and Stay All Remaining Proceedings (ECF 74);

WHEREAS, Plaintiffs filed a second motion for leave to amend their Complaint to add or substitute a party on April 1, 2014 (ECF 84) and April 9, 2014 (ECF 90) seeking to add "eoBuy Licensing Limited" as a plaintiff;

WHEREAS, on April 9, 2014, Plaintiffs filed a Motion Requesting an Enlargement of Time to Submit a Corrected Response and/or Renew their Response to the Defendants' Motions to Compel Arbitration, Dismiss or Stay Proceedings (ECF 91) to include "eoBuy Licensing Limited" as a plaintiff in response to Defendants' motions;

WHEREAS, on April 17, 2014, the case was transferred to the Honorable Vince Chhabria pursuant to the Order Reassigning Case;

WHEREAS, the Order Reassigning Case vacated all case management conference dates and motion hearing dates;

WHEREAS, the Parties have conferred and have re-noticed all pending motions for Thursday, June 5, 2014 at 1:30 p.m.;

WHEREAS, the Parties have conferred and still agree that it would be inefficient to plan discovery, motions and other case management processes, including the Court's ADR Multi-Option Program, for a case in which one plaintiff may be dismissed and that may be ordered to binding arbitration where different rules and procedures will govern;

WHEREAS, notwithstanding the above, Plaintiffs have informed Defendants of their intent to file a motion seeking expedited discovery of certain electronic evidence from Defendants Rooke and Rogness also to be heard on Thursday, June 5, 2014 at 1:30 p.m.;

ACCORDINGLY, it is hereby stipulated and requested pursuant to Civil L.R. 6-2(a), by Indiezone, Inc. and eoBuy, Limited (together, "Plaintiffs"), and Defendants Jingit LLC, Jingit Holdings, LLC, Jingit Financial Services, LLC, Todd Rooke, Joe Rogness, Phil Hazel, Sam Ashkar, Holly Oliver, Shannon Davis, Justin James, Chris Ohlsen, Dan Frawley, Dave Moorehouse, II, Tony Abena, Chris Karls, John E. Fleming, Music.Me, LLC, U.S. Bank National Association, Target Corporation, Wal-Mart Stores, Inc. and General Electric Company (together, "Defendants"; Plaintiffs and Defendants collectively, the "Parties"), through their respective counsel as follows:

This Stipulation and Request is supported by the attached Declaration of Counsel Pursuant to Civil L.R. 6-2(a).

PURSUANT TO STIPULATION, IT IS SO ORDERED.